The UBO register came into effect on 27 September 2020. From that date, the ultimate beneficial owners (“UBOs”) of (virtually) all new companies and other legal entities registered in the trade register must be registered in a central and public register. Existing companies and other legal entities must register their UBOs within 18 months of the entry into force, i.e. no later than March 26, 2022.

Which entities are required to register their UBOs?
  • BVs and NVs
  • Foundations (also the trust office foundation), associations, cooperatives and mutual insurance associations
  • Partnerships, limited partnerships (CVs), general partnerships (VOFs)
  • Churches and shipping companies
  • European Public Limited Companies (SEs), European Economic Interest Groupings (EEIGs) and European Cooperative Companies (SCEs) with registered office in the Netherlands

The exceptions to this are the listed company and its 100% subsidiary, the Association of Owners and the association without full legal capacity and without a company.

Sole proprietorships, legal entities under public law and other legal entities under private law (almshouses, guilds, foundations and farmer's markets) also do not have to register a UBO(s).

Who qualifies as a UBO?

The ultimate beneficial owner for the UBO register is the natural person who is the ultimate owner of or has control over a company or other legal entity. Among other things, the holding of shares, voting rights, ownership interest, other resources and effective control are examined. The qualifications of who must be regarded as a UBO differ per company and other legal entity.

What can we help you with?
  • We can map out which information must be included in and supplied to the UBO register.
  • We are happy to think along with you about how you can control this as much as possible.
  • We provide you with administrative support for the registration and maintenance of this obligation.
2021: UBO register for trusts and similar legal constructions

Finally, the UBO register for trusts and similar legal constructions will also come into effect in the course of 2021. According to the bill, the UBOs of a Fund for Common Account will have to be registered in this so-called second UBO register. As soon as more information is available, it will also be posted on our website.